[arin-ppml] 2014-1 Out of Region Use

[Ted Mittelstaedt]

Hi Milton and All,

   I am concerned with the following:

"ARIN reserves the right to request a listing of all the applicant's 
number holdings in the region(s) of proposed use, but this should happen 
only when there are significant reasons to suspect duplicate requests."

   I feel this should be changed to the following:

"ARIN reserves the right to request a listing of all the applicant's 
number holdings in the region(s) of proposed use"

   I don't believe that it is good policy to micromanage people.  Either
you trust the RIR or you don't.  if you are writing policy for the RIR 
that to me indicates you trust the RIR.

   If ARIN decides to pull a listing of applicant holdings, they are 
going to have some suspicion there's fraud or other duplicate requests
going on.  If the request is legit, then the requestor isn't going to
have a problem showing ARIN this listing.  But if the request is 
fraudulent, then the requestor is going to use every hook possible
to fight ARIN and your handing them a weapon with this "significant
reasons" thing.  "Significant reasons" are not defined elsewhere in
the policy manual, and your just asking the requestor to threaten
to sue ARIN over a difference of interpretation of that statement.

If you feel this strongly about it please just say:

"ARIN reserves the right to request a listing of all the applicant's 
number holdings in the region(s) of proposed use, but this should happen 
only when duplicate requests are suspected."

I also think a /22 of IPv4 is too small a litmus test and a real
multi or trans-regional network is going to have more IP numbering
in play, but I recognize that this is a separate fight that needs to
be argued over during a different time.

Ted



On 10/21/2014 7:20 AM, Milton L Mueller wrote:
>
> Based on feedback from NANOG, our Baltimore general meeting, and the AC meeting and list I have revised 2014-1 for what I hope is the last time. I have updated the Wiki and am requesting staff and legal review.
>
> I believe the proposal is technically sound, enables fair and impartial resource allocation and has widespread community support .
>
> Full amended text below. Note that I have also amended the problem statement to reflect the revisions. The earlier text about defining out of region use, engagement of external entities, etc is no longer needed and thus is gone. The comments section is also modified to reflect the overall simplification.
>
> Milton L. Mueller
> Laura J. and L. Douglas Meredith Professor Syracuse University School of Information Studies http://faculty.ischool.syr.edu/mueller/mueller/Home.html
>
> ===
>
> Draft Policy ARIN-2014-1 Out of Region Use
>
> Date: 21 October 2014
>
> Problem statement:
> Current policy neither clearly forbids nor clearly permits out or region use of ARIN registered resources. This has created confusion and controversy within the ARIN community for some time. Earlier work on this issue has explored several options to restrict or otherwise limit out of region use. None of these options have gained consensus within the community. The next logical option is a proposal that clearly permits out of region use while addressing some of the concerns expressed about unlimited openness to out of region use.
>
> Policy statement:
>
> Create new Section X:
>
> ARIN registered resources may be used outside the ARIN service region. Out of region use of IPv4, IPv6, or ASNs are valid justification for additional number resources if the applicant is an ARIN member in good standing and is currently using at least the equivalent of a /22 of IPv4, or a /44 of IPv6, or 1 ASN within the ARIN service region, respectively.
>
> The services and facilities used to justify the need for ARIN resources that will be used out of region cannot also be used to justify resource requests from another RIR. When a request for resources from ARIN is justified by need located within another RIR's service region, an officer of the applicant must attest that the same services and facilities have not been used as the basis for a resource request in the other region(s). ARIN reserves the right to request a listing of all the applicant's number holdings in the region(s) of proposed use, but this should happen only when there are significant reasons to suspect duplicate requests.
>
> Comments:
> a. Timetable for implementation: Immediate b. Anything else Current policy is ambiguous on the issue of out of region use of ARIN registered resources. The only guidance on the issue in current policy is Section 2.2, which defines the the role of RIRs as "to manage and distribute public Internet address space within their respective regions." Some in the community believe this means out of region use should be prevented or restricted, while others believe this is only intended to focus efforts within the region and not define where resources may be used.
> Previous policy proposals have explored restricting or otherwise limiting out of region use, but none have gained consensus within the ARIN community. Several standards for restricting out of region use were explored, but all of them were perceived as interfering with the legitimate operations of multi- or trans-regional networks.
> The requirement to have a minimal level of resources deployed in the region (/44 for IPv6, /22 for IPv4, 1 ASN) is an attempt to respond to law enforcement and some community concerns. An absolute threshold ensures that those applying for ARIN resources are actually operating in the region and not simply a shell company, but it avoids the known pitfalls of trying to use percentages of the organization's overall holdings to do that. The use of officer attestation and the possibility of an audit is an attempt to prevent duplicate requests without requiring burdensome reporting requirements.
> In summary, this proposal ensures that trans-regional organizations or service providers operating within the ARIN region may receive all the resources they need from ARIN if they wish to do so. This change is particularly important for IPv6. Requiring organizations get IPv6 resources from multiple RIRs will result in additional unique non-aggregatable prefixes within the IPv6 route table.
>
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